Request For Careful Reconsideration of HVCC

The Home Valuation Code of Conduct ("HVCC") stands to be an important step forward for consumers and the Real Estate industry, but in its current form there are some important changes that require your attention.

In its current form, Consumers have a great deal at stake as HVCC will not only require consumers to buy a new appraisal if they decide to change brokers or lenders, but will have to pay for longer rate locks as HVCC will extend the time it takes to close mortgage loans and deprive mortgage brokers and agents of the control that is fundamental in closing mortgage loans efficiently. Ultimately, this means costs are increased for consumers and there is less incentive for consumers to exercise their right to shop for the best deal when acquiring a mortgage as doing so requires purchasing an entirely new appraisal.

The HVCC is also discriminatory against mortgage brokers, appraisers, and real estate agents. The HVCC stands to eliminate independent Appraisers overnight by requiring them to join Appraisal Management Companies (AMC's) in order to continue doing business. After joining an AMC appraiser will be disgorged of 40\% or more of their income as a fee required by AMC's. This not only means the end of the Independent Appraiser as we know them, but means that virutally half of Appraiser's incomes will be shifted to unregulated entities, AMC's.

HVCC has great potential, but only if careful consideration is given to the existing flaws that will only serve to hurt consumers, brokers, agents, and appraisers. We humbly ask for your help in helping HVCC live up to its true potential. Thank you.